Allocation of Roles under the PPWR: Who Bears Which Responsibility?

07/21/2026 | 4 min read

Anita Gruber

Anyone working with packaging quickly realizes that clear responsibilities along the value chain are increasingly important. The Packaging and Packaging Waste Regulation not only introduces new sustainability requirements for packaging but also establishes for the first time a uniform EU-wide definition of which economic operators carry which obligations throughout the packaging lifecycle.

At the core is a simple yet crucial idea: to verify whether packaging complies with PPWR requirements, companies must know what role they play and which obligations come with it. 

This allocation of roles is not merely a classification scheme; it is the foundation for clearly assigning duties, requirements, and responsibilities. Only those who know their role can ensure that packaging not only meets legal requirements but also generates the necessary compliance documentation that may be requested by market surveillance authorities.   

In short: the PPWR role allocation precisely defines who assumes responsibility in the system and what requirements are associated. This provides a practical starting point for companies preparing for upcoming obligations.

Roles in the Packaging Market

The following defines the key roles in handling sales packaging and highlights the respective duties and responsibilities. This makes it clear which requirements companies must meet to place packaging on the market in compliance with the law.

A particular challenge is that companies often simultaneously occupy multiple roles within the packaging supply chain. This means they must fulfill the obligations of each role they hold and clearly document and organize responsibilities to reliably comply with PPWR requirements.

Duties Regarding Material and Information

Supplies packaging or packaging materials to a manufacturer.

Under the PPWR, a supplier does not include those delivering packaging or materials to other customers, such as distributors, or recipients outside the EU.

Supplier obligations include, among others:

Providing all information and documentation the manufacturer needs for conformity assessment (including data on materials, recycled content, design requirements, and chemical specifications)
Supplying technical information in paper or electronic form
Ensuring that delivered materials comply with Articles 5-12 (recycled content, design for recycling, material labeling, etc.)
Traceability of delivered material batches

Suppliers are crucial for transparency and traceability along the chain. Without them, manufacturers cannot fulfill their obligations.

Duties Regarding Assembly

Performs the final processing steps on packaging supplied by the packaging supplier and fills it with their product to place the packaging or packaged product on the EU market.

Manufacturer obligations include, among others:

Compliance with all requirements from Articles 5-12 (material requirements, recycled content, recyclability, labeling)
Performing or commissioning conformity assessment (Article 38)
Creating technical documentation (Annex VII)
Ensuring unambiguous identification (type, batch, or serial number)
Labeling the packaging or providing information via a data carrier (QR code, etc.)
Preparing and maintaining the EU declaration of conformity

Manufacturers act as the interface between supplier information and producer responsibility and play a key role in ensuring packaging is compliant. Exceptions apply for brand owners and micro-enterprises.

There can be only one manufacturer per EU member state. Manufacturer obligations may be transferred to an importer or distributor/retailer.

Duties Regarding Placing on the Market

Any manufacturer, importer, or distributor who places packaged products on the market for the first time in the same member state or directly to end consumers in another member state is considered a producer. The producer is responsible for packaging in the EU member state where it becomes waste and bears the obligation of extended producer responsibility for packaging waste. Therefore, there is one producer per EU member state.

Producer obligations include, among others:

Registration in the producer register
Payment of EPR fees

Case Study: Role Allocation Using K3® r100

To illustrate how PPWR role allocation works in practice, let’s look at a concrete product. The innovative, self-separating K3^® r100 cup from Greiner Packaging demonstrates how various economic operators interact and what obligations each bears.

The following shows which actor in the packaging chain assumes which role when yogurt is marketed in a K3^® r100 cup.

Greiner Packaging:

For the K3^® r100, multiple companies act as suppliers. Greiner Packaging (assumed for this example: a Czech site) supplies the empty cup including the cardboard sleeve (packaging component), while other suppliers produce the lid.

Customer of Greiner Packaging (Manufacturer):

In our example, a company in Germany fills the yogurt or other product into the K3® r100 cup and seals it with the lid insert. Only through this step does the final, ready-to-use packaging emerge. In practice, the manufacturer role is primarily assumed companies producing food products. Exceptions exist for micro-enterprises or contract manufacturing.

Producer of the Packaging:

Who qualifies as a producer depends on where the packaging eventually becomes waste:

Germany: If the yogurt cup is placed on the German retail market and is therefore consumed and disposed of there, the manufacturer (the customer of Greiner Packaging) is also the producer.
Export to another EU member state: If the cup is supplied to a retailer in another EU member state, e.g., Austria, that retailer is considered the producer.
Direct sales to end consumers in another EU member state, e.g., Belgium: If direct sales occur in other EU countries without intermediaries, e.g., via the manufacturer’s online shop, the producer role remains with the manufacturer.

This differentiated approach is necessary because the producer role is always tied to the location where the waste arises.

Conclusion

The PPWR makes it clear that clear roles and responsibilities along the supply chain are crucial for reliable implementation. Suppliers, manufacturers, producers, distributors, and importers must know and fulfill their obligations.

A clear understanding of role allocation allows risks to be targeted, processes to be made transparent, and ensures that packaging is placed on the market in compliance with the law. Those who understand the tasks of each actor and organize collaboration effectively create transparency, legal certainty, and a solid foundation for PPWR compliance.

_{Disclaimer: It is important to note that role allocation in practice is complex and can vary depending on the case. A universally applicable definition is therefore difficult to establish. This article is for general informational purposes only and does not constitute legal advice. The information provided reflects our current knowledge at the time of publication and may be subject to change.}